Omission to Disallow Interest on Unexplained Loans is Error – 263 Jurisdiction Valid

Dhanesh Badarmal Jain Vs PCIT (ITAT Ahmedabad) Assessee filed return for AY 2021-22 declaring income of ₹4.99 lakh. In scrutiny, AO noticed unsecured loans of ₹1.36 crore, out of which ₹92 lakh was fresh loans from 10 parties & the balance ₹44.51 lakh was interest accrued thereon. As assessee failed to prove identity & creditworthiness of creditors, AO added ₹92 lakh u/s 68 as unexplained loans, besides addition of ₹14 lakh unexplained cash deposit, & completed assessment at ₹1.10 crore. PCIT later invoked revision u/s 263, observing that AO erred in not disallowing t...